In re John, No. 5:08-bk-52505-JJT, 2012 WL 1998405, at *4 (Bankr. M.D. Pa. June 4, 2012) (Thomas)

“I agree with the majority of Courts that Section 109(h) is not jurisdictional.” Although debtors did not satisfy § 109(h) because briefing certificate was dated more than 180 days before the petition, technical noncompliance is excused when debtors have completed payments under the plan and no prejudice is apparent by entry of discharge and closing of case.

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